Sumitomo Corporation Global Commodities Limited – Modern Slavery and Human Trafficking Statement for the Fiscal Year 2023

Sumitomo Corporation Global Commodities Limited is committed to improving its practices to combat modern slavery and human trafficking. This statement has been published in accordance with the UK Modern Slavery Act 2015 and constitutes Sumitomo Corporation Global Commodities Limited’s modern slavery and human trafficking statement for the fiscal year 2023 ended 31st March 2024. This statement was approved by the board of directors of Sumitomo Corporation Global Commodities Limited on 19th June 2024.

The organisation’s structure, its business and its supply chains

Sumitomo Corporation Global Commodities Limited (‘SCGC’) is a dealer in commodities and commodity derivatives in the wholesale markets, specialising in precious metals, base metals, and energy derivatives. It has its head office in London and a branch office in Singapore and is regulated in the United Kingdom by the Financial Conduct Authority. SCGC sources all physical commodities from regulated markets or in the case of precious metals, from suppliers who are approved and regularly audited by the London Bullion Market Association (LBMA) under the LBMA’s Responsible Sourcing Programme.

Steps taken to ensure that modern slavery and human trafficking are not taking place in SCGC’s business and supply chains

SCGC, as a member of the Sumitomo Corporation (SC) Group, shares Sumitomo’s Business Philosophy, which has been passed down and followed faithfully for more than 400 years since Masatomo Sumitomo (1585-1652) had founded. SC Group’s Corporate Mission Statement (Management Principles and Activity Guidelines) is based on this philosophy and represents SC Group’s fundamental and ultimate value standard. In the Corporate Mission Statement, it clearly states that SC Group respects the personality of each individual and places prime importance on integrity and sound management.

SCGC takes its commitment to tackling modern slavery and human trafficking very seriously. We set out below the steps we have taken to help ensure that modern slavery and human trafficking are not taking place in our business or supply chains:

The SC Group’s Human Rights Policy

SCGC respects “the International Bill of Human Rights” and the International Labor Organization’s “Declaration on Fundamental Principles and Rights at Work”, and we operate in accordance with “the United Nations Guiding Principles on Business and Human Rights”.

As a member of the SC Group, in line with the SC Group’s Human Rights Policy, SCGC confirms that: (i) we strive to identify and to prevent or mitigate any adverse impact on human rights through the implementation of human rights due diligence processes; (ii) where we identify that our group’s practices have caused or contributed to an adverse impact on human rights, we will endeavour to take appropriate remedial measures; and (iii) we will seek to improve and progress human rights measures through engagement and dialogue with relevant stakeholders.

The SC Group’s CSR Action Guidelines for Supply Chain Management

SCGC acts in accordance with the SC Group CSR Action Guidelines for Supply Chain Management. Through the implementation of these guidelines, we are aiming to realize a sustainable society by working together with our suppliers, business partners and contractors, etc. to achieve responsible value chain management. As part of these guidelines, we set out its values to “Respect human rights and not to be complicit in human rights abuses” and to “Prevent forced labor, child labor and the payment of unfairly low wages.” These principles establish the overarching guidelines encompassing our commitment to combating modern slavery and human trafficking.

In the event that we find violations of these guidelines in our supply chains, we will urge the suppliers, business partners or contractors, etc. to remedy and improve the situation, while providing support to them as needed. However, if there are no improvements to the situation by them, we will consider carefully whether to continue our business with them or not.

Enhancement of SC Group Governance

As a member of the SC Group, SCGC is collaborating with SC on “Enhancement of SC Group Governance” aiming to improve business quality and corporate value through internal control. Specifically, we have introduced a governance framework that uses SC Group’s standard tool called Basic Elements to visualize the internal control status of each group company and solve issues identified through “dialogue” with the parent company.

The Basic Elements include “Respect for Human Rights”, “Labor Management, Health, Safety and the Environment”, and “Supplier Management”, and if there are issues, we formulate a response policy according to its business nature and regional conditions. Through regular monitoring, we will continue working to prevent modern slavery and human trafficking in our business or supply chains through further enhancing governance considering its business nature and regional conditions.

Training

In order to raise our awareness especially about modern slavery, SCGC utilizes an American NGO Verite’s free e-Learning on Supply Chain Accountability on forced labour as a useful training material, which is one of the referred tools on ‘Transparency in Supply Chains: A Practical guide’ published by UK Home Office, and has provided a mandatory online training module for staff on the prevention of modern slavery.

SCGC believes that eradication of modern slavery is important, and we will continue to undertake these efforts aimed at ensuring that no modern slavery or human trafficking of any form exists in our business and supply chains.

[This statement was approved by the Board of Directors of Sumitomo Corporation Global Commodities Ltd on 19th June 2024 and signed by Mr. Peter Drabwell, Managing Director on that date.]